FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing
FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing
FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing
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(As Against Faegre & Benson, Fischer, & Judy Heumann)<br />
59. Plaintiff incorporates by this reference each of the<br />
previous paragraphs. Plaintiff repeats and re-alleges each and<br />
every allegation contained in the previous paragraphs.<br />
60. Faegre & Benson, Fischer and Heumann willfully<br />
disobeyed the Judgment On Remand by the Fabricated Order.<br />
61. Faegre & Benson, Fischer and Heumann interfered with<br />
the ability of the Court to function properly by the Fabricated<br />
Order.<br />
62. As a direct and proximate result of foregoing, Faegre &<br />
Benson, Fischer and Heumann should be held in contempt, and ISR<br />
awarded damages, together with interest, costs and reasonable<br />
attorneys’ fees and declaratory and/or injunctive relief.<br />
NINTH CAUSE <strong>OF</strong> ACTION<br />
(Declaratory Relief)<br />
(As Against All Defendants)<br />
63. Plaintiff incorporates by this reference each of the<br />
previous paragraphs. Plaintiff repeats and re-alleges each and<br />
every allegation contained in the previous paragraphs.<br />
64. There is an actual controversy between the parties.<br />
65. A judicial determination is required regarding the<br />
Fabricated Order. Defendants have taken the position that the<br />
Fabricated Order is a true and correct Order of this Court and is<br />
properly filed with the Boulder County Clerk and Recorder. ISR<br />
has taken the position that the Fabricated Order was never issued<br />
or entered by this Court and was not properly filed with the<br />
Boulder County Clerk and Recorder and should be voided.<br />
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